On 26 May 2025, the CSSF published Version 8 of its FAQs on the AML/CFT Market-Entry Form (“MEF”) relating to the completion of the MEF to be submitted via eDesk. This document provides clarifications on the circumstances in which the MEF must be submitted or updated, and on the information and documents required by the CSSF.
The FAQ is maintained by the CSSF and may be updated from time to time to reflect changes in regulatory expectations or administrative practices. Version 8 replaces the previous version dated 21 December 2023.
The FAQ in a nutshell
Submission of the MEF
The updated FAQ reiterates that the MEF must be submitted not only upon initial market entry, but also upon occurrence of a “trigger event”, such as the launch of a new sub-fund, the addition of a new qualified shareholder, or the appointment of a new responsable du contrôle ("RC") or responsable du respect des obligations ("RR").
Distinction between initial and update filings
The FAQ clarifies that a MEF must be submitted upon initial registration, as well as upon the occurrence of a trigger event.
Documentation of individuals
Directors, managers, and other individuals already approved by the CSSF are no longer required to resubmit their CV, ID, or criminal record, provided that the previous submission is properly referenced. Conversely, newly appointed individuals – in particular the responsable du contrôle – must submit all required documents and identification forms.
Submission channels
Depending on the nature of the update, the MEF and supporting documentation must be submitted via the CSSF’s eDesk platform. In case of a trigger event (e.g. new sub-fund, appointment of a new RR or RC, new qualified shareholder), the relevant MEF request must be selected in eDesk. For ELTIFs outside the scope of Part II, SIF or SICAR, identification-only updates must be submitted via eDesk using the option “Market entry OTHER LU AIF (ELTIF) – notification update”, and the CSSF must also be notified by email.
Signature requirements
The CSSF confirms that both wet-ink and electronic signatures are acceptable, provided that appropriate measures are taken to prevent any post-signature alteration.
Sub-fund updates
When a new sub-fund is added and triggers one of the specified events (e.g. new initiator, new founder, limited investor base, or new investment type), a single MEF must be submitted via eDesk for the umbrella fund. The MEF must include complete and up-to-date information for all existing and new sub-funds. No separate MEF is required per sub-fund.
“Known to the CSSF” status
The FAQ clarifies that this status applies to portfolio managers or investment advisors not authorised by the CSSF, but already acting in the same capacity for other funds authorised by the CSSF.
New clarifications introduced in version 8
ELTIF notification updates
A new procedure applies to authorised ELTIFs outside the scope of Part II, SIF or SICAR. If only the identification of a director, RR or RC changes, the MEF must be submitted in eDesk under “Market entry OTHER LU AIF (ELTIF) – notification update”, with supporting documents uploaded, and the CSSF must be notified by email.
Article 3(2) AIFMs
The CSSF confirms that AIFMs registered under Article 3(2)(a) or (b) of the AIFM Law are only required to submit the MEF at the time of initial registration. No further update is required unless specifically requested by the CSSF. However, any substantial change must be notified separately by email.
This update serves as a reminder to ensure that all AML/CFT governance documents and procedures are up to date, and that the appropriate version of the MEF is submitted in line with the nature of the change and the regulatory status of the fund or IFM.
BSP remains available to assist with the preparation, review, and submission of the MEF in accordance with the CSSF’s latest expectations.
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